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Archive for author: Sarah Guasta

Final Rule Suspending Expansion of End-User Controls to Cover Affiliates of Certain Listed Entities (“50%” Rule)

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In this final rule, the Bureau of Industry and Security (BIS) imposes a one-year suspension of the interim final rule, ‘‘Expansion of End-User Control...

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Enhanced End-User Controls (“Affiliates Rule”) Suspended for One Year

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The United States will suspend for one year, starting on November 10, 2025, the implementation of the interim final rule titled Expansion of End-User ...

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Status of Government Export Related Activitie

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DDTC- DDTC has resumed limited operations. Services currently available include registration renewals and licensing. Certain support functions may rem...

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ITAR Cambodia Licensing Policy Change, Effective October 26, 2025

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DDTC has removed the arms embargo on Cambodia.  DDTC is now reviewing license applications for ITAR-controlled activities on a case-by-case basis for ...

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Sanctioned Parties Screening During Government Shutdown

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Neither the Consolidated Screening List, nor the EAR on the BIS website have been updated with these parties.  While the government is closed, neither...

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Entity List Affiliates Rule and the Consolidated Screening List

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The adoption of the Affiliates Rule will mean that the Consolidated Screening List (CSL) will no longer comprise an exhaustive listing of foreign enti...

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Commerce/BIS Amends EAR Parts 732, 734, 736, 744, and 748 to Expand End-User Controls

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In this interim final rule (IFR), the Bureau of Industry and Security (BIS) amends the Export Administration Regulations (EAR) to address diversion co...

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Recission of the 2024 Firearms IFR

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On April 30, 2024, the Bureau of Industry and Security (BIS) published an interim final rule (Firearms IFR) that imposed new export license requiremen...

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Government Shutdown

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Both the U.S. Commerce Department/BIS and U.S. State Department/DDTC are effectively closed. Our firm is currently able to draft and prepare license a...

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BIS Closes Export Controls Loophole for Foreign-Owned Semiconductor Fabs in China, Relaxes Controls for Syria

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The Department of Commerce’s Bureau of Industry and Security (BIS) have closed a Biden-era loophole that allowed a handful of foreign companies to exp...

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